While the HCSP is not specifically addressed in the Affordable Health Care Act (ACA), the plan shares some similarities with a Health Reimbursement Arrangement (HRA). Therefore, in an abundance of caution, employers are encouraged to file a Form 1094/1095 to report months in which a retired or inactive employee had an HCSP account balance. MSRS will provide the HCSP information at the employer's request.
What employers should do
You are encouraged to consult with a tax or legal professional to determine if they believe (as we do) that HCSP is minimum essential coverage for retired or terminated employees and therefore, reportable.
To request a report of employees who had an HCSP balance during 2020 email email@example.com
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